Industrial and Hazardous Waste Permits IHW Section Process

Industrial and Hazardous Waste Permits (I&HW) Section Process Enhancements Chirag Patel Fabienne Rambaud P. G. Industrial & Hazardous Waste Permits May 15, 2019 Environmental Trade Fair 2019

Do you know how long it takes for an application to be processed? • New permits, renewals, Class 3 modifications from submission to technically complete (Up to 143 days are dedicated to technical review) We are working on a process to cut this time in half! 50% less processing time! HOW? 2

How To Cut time? By streamlining processes What are the changes? 1. Renewal Call-In letters 2. Pre-application Meeting Checklist 3. Review and Return Policy 4. Improved Part B Permit Application Form/Format & Submittal Process 3

1. Renewal Call-In Letters 4

Renewal Call-In Letters • Now they will be sent 18 months before permit expiration date instead of 12 months • Will provide renewal application submission deadline • Will provide instructions and required actions 5

Renewal Call-In Letters • Will highlight the requirements for RCRA Part B Administrative and Technical Evaluation checklist • Will ask you to schedule a pre-application meeting with us at least 1 year before the permit expiration date • Please note that I&HW is willing to have multiple preapplication meetings to assist applicants 6

Renewal Call-In Letters • Will inform you of changes to I&HW program • This will let you comply with regulations • Will reduce review time Result: a quicker and better permit 7

2. Pre-application Meeting Checklist 8

Pre-application Meeting Checklist (TCEQ-20846) • You will fill it out before your pre-application meeting • You will discuss your proposed changes to your permit • You will review the modification classes Class 1 ED Major Amendments Class 2 Class 3 Minor Amendments Renewals 9

Pre-application Meeting Checklist (TCEQ-20846) 1. Inform the I&HW Project Manager (PM) who will be attending 2. Submit a copy of the meeting agenda to the I&HW Project Manager at least five days prior to the meeting listing the highlights of the application request 10

Pre-application Meeting Checklist (TCEQ-20846) 3. Be aware of the applicant-held pre-application public meeting required [(30 TAC 39. 503(b)] for the following three application types prior to submitting your application: • New applications • Renewal applications with Class 3 Permit Modifications/Major Amendments • Major Amendment applications 11

Pre-application Meeting Checklist (TCEQ-20846) 4. Prepare a Power. Point or Word document of the highlights of the application request i. e. , • facility type • application type • facility operation and management • waste management units involved • and any other applicable items 12

Pre-application Meeting Checklist (TCEQ-20846) 5. Be aware of the required TCEQ Part B Administrative and Technical Evaluation Checklist (TCEQ-00136) and list any questions you may have in the meeting agenda 13

Pre-application Meeting Checklist (TCEQ-20846) 6. Be ready to discuss communication preferences at the pre-application meeting • Preferred Contact Person (e. g. consultant, facility) • Preferred Contact Format (e. g. emails, phone calls, formal letters) 14

Pre-application Meeting Checklist (TCEQ-20846) 7. Remember to use the Waste Permit Division (WPD) Correspondence Cover Sheet (TCEQ 20714) when you submit your application 15

Pre-application Meeting Checklist (TCEQ-20846) 8. Refer to the requirements in the Part A and Part B Application Forms and the RCRA Application Format, be prepared to comply with these requirements when submitting your application, and list any questions you may have in the meeting agenda regarding these requirements 16

Pre-application Meeting Checklist (TCEQ-20846) 9. Add any other items you wish to discuss 17

3. Review and Return Workgroup 18

Overview • I&HW section has a review and return policy on applications and materials to be submitted to TCEQ • Continuous Process Improvement include: • Standardization requirements of modifications and reports • Streamline record keeping • Policy to return deficient applications 19

Background • Standard Modification templates have been updated to promote consistency • Applicant will receive an approved modification sheet along with Table of Permit Modifications and Amendments • In lieu of paper copies, I&HW will email and transmit Class 1 modifications to applicants • Allows for faster response to Class 1 modifications 20

Streamlining • Elimination of submittal of Annual Waste Minimization Certification to I&HW • Waste Minimization Certification are to be kept with facility operating records (40 CFR 264. 73) • Does not affect Annual Source Reduction and Waste Minimization Report (30 TAC Chapter 335 Subchapter Q). 21

Return of Applications • Incomplete applications (missing application materials, figures, signatures etc. ), or deficient may be returned to applicant prior to administrative completeness on a case-by-case basis. 22

Reminders! • Including these in your report or application makes the review and approval process smoother. • Correspondence Cover Sheet, (TCEQ-20714) • TCEQ Core Data Form, (TCEQ-10400) • If applicable, include Part B Application Checklist 23

Communications with I&HW • Contact I&HW Permits Section to have a preapplication meeting • We can help review application requirements and answer questions to help you ease through the permit application process 24

4. Improved Part B Permit Application Form/Format & Submittal Process 25

Objectives • Provide a standard application • Clarify the submittal requirements • Streamline the preparation process for applicants • Streamline the review process for project managers • Reduce deficiencies 26

Part B Application Enhancement & Streamlining Overview • Breaks up the applications into 3 parts • Instructions • Forms • Tables, Certification statements • Electronic application screening tool for use by the applicant to screen facility specific information: • Regulatory requirements • Applicable tables/attachments • Applicable application format 27

Part B Application Enhancement & Streamlining Overview • Each Part B table will be hyperlinked individually in pdf format for use by the applicant • Section/Appendix cover pages • Required documents 28

Physical Application Format • Divided into sections • Follows Part A and Part B applications forms • Required information listed for each section • Required forms responses & applicable regulations • Table & Attachments • Reports, etc. 29

Electronic Part B Application Screening Tool • Creation of Appendices & Format based on Screening Questions • Required information listed for each section • Required form responses & applicable regulations • Table & Attachments • Reports, etc. • Enhanced PDF tables 30

Electronic Part B Screening Tool Standard Part B and Enhanced Part B Application will be PDF format (Demonstration of Enhanced Application) 31

Electronic Part B Screening Tool 32

Electronic Part B Screening Tool 33

Electronic Part B Screening Tool 34

Webpage Updates Standard Part B and Enhanced Part B Applications will be added to webpage when finalized 35

Have you signed up for the latest I&HW waste news from TCEQ? • Keep up-to-date on changes that are occurring with I&HW in Texas • Sign up today at https: //www. tceq. texas. gov/goto/ihwgovdev. 36

More Information, Questions on Industrial & Hazardous Waste Management? Contact the Industrial & Hazardous Waste Permits Section at: (512) 239 -2335 or ihwper@tceq. texas. gov 37